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RUNNING HEADER: GENETICALLY MODIFIED ORGANISMS AND THE LAW

Genetically Modified Organisms and the Law

Chloe Cohen
First Colonial High School
Legal Studies Academy

GENETICALLY MODIFIED ORGANISMS AND THE LAW

Abstract
This paper investigates how genetically modified organisms (GMOs) are tied to various aspects
of society and law. Following the introduction, it explains the top agrochemical companies
involvement in this issue, from company history to lobbying contributions. The author
emphasizes the dominance that only four companies have over a disproportionately large sector
of the seed market, examining various political implications, as well as the health, ecological,
and economic effects caused by this control of the market. The final section of this paper extends
the analysis into the legal field, examining both GMOs significance in case law and black letter
law. It discusses information about the most important cases in this issue and compares labeling
efforts in the United States to the current labeling regulations in the European Union. Finally, it
wraps up the paper by reminding the reader that although it is difficult to reverse the negative
effects of the genetically engineered seed industry, a major step in beginning to counteract these
implications is the implementation of a national policy on labeling products that contain GM
ingredients.

GENETICALLY MODIFIED ORGANISMS AND THE LAW

Genetically Modified Organisms and the Law
Seventy percent of all American foods contain genetically modified ingredients (Hauter,
2015). Moreover, several foods are at an even higher risk for being genetically modified than
others; as of 2011, 88% of corn, 90% of canola, 90% of cotton, 94% of soy and 95% of all sugar
beets grown in the United States are indeed GMO crops. If a food contains yeast products, amino
acids, vitamins, aspartame, xanthan gum, ascorbic acid, textured vegetable protein (TVP), citric
acid, sucrose, monosodium glutamate, sodium citrate, molasses, ethanol, natural or artificial
flavorings, maltodextrins, high-fructose corn syrup, lactic acid, or hydrolyzed vegetable protein,
chances are that the food contains GMOs ("What Is GMO?," n.d.). However, Americans continue
to buy these products without any knowledge that they are consuming genetically modified
ingredients.
According to the Non GMO Project, GMOs are organisms whose genetic material has
been artificially manipulated in a laboratory through genetic engineering, or GE ("What Is
GMO?," n.d.) GMOs are labeled in 28 European Union nations, China, Japan, Russia, and
Australia, but not in the U.S. ("Why Label?," n.d.). Labeling genetically modified organisms will
give consumers access to information that can help them make more informed decisions,
decrease unintended ecological consequences of GM crops, and minimize the disproportionate
amount of political control that currently belongs to companies responsible for this genetic
engineering.
History of GMOs and Their Driving Companies
Monsanto
The Monsanto Company began in 1901 by producing saccharin, an artificial sweetener.
Over the years, Monsanto has transitioned from making this substance to manufacturing basic
industrial chemicals, contributing to the Manhattan Project and the atomic bomb, to fabricating
synthetic plastics and fibers. The herbicides 2, 4, and 5-T and the more notorious chemicals:

GENETICALLY MODIFIED ORGANISMS AND THE LAW

Agent Orange; PCBs; DDT; and Roundup, were produced later in the century. Agent Orange was
used during the Vietnam War and caused health complications for over 3 million people, due to
its high dioxin levels. Furthermore, half a million children have experienced deformities at birth,
thanks to Agent Orange. In 1976, Monsanto launched Roundup, later to introduce its Roundup
Ready seeds from which Roundup-resistant plants grow another revolutionary development in
Monsanto history (GMWatch, 2009).
The price of Roundup has increased dramatically as a result of Monsantos control of the
market. Globally, Roundup remains the pesticide best-seller, while Monsantos first biotech
product, its GM drug for cattle, has received volumes of negative publicity (GMWatch, 2009).
This drug, rBST or rBGH, causes cows to produce about 10% more milk, but it has given the
cows mastitis, reproductive problems, and lameness (Organic Consumers Association, n.d.). As
of 2009, Monsanto is number five on the list of the worlds largest agrochemical companies
(GMWatch). Out of the area dedicated to GM seeds in the entire world, Monsanto was
accountable for 87% (Cook).
DuPont Company
leuthre Irne du Pont founded DuPont Company in Delaware, 1802. The companys
main focus at that time was blasting powder. It created the first industrial explosive, called soda
powder, in 1857. Twenty-three years later, the company started to manufacture dynamite and
nitroglycerin. Next, DuPont developed nitrocellulose for products such as leather finishes and
lacquers in 1904. In 1915, the company added nitrocellulose plastics to its list. DuPont also
pioneered neoprene, nylon, Dacron polyester, Lucite, Tyvek, Teflon, Orlon, Kevlar and Mylar.
Although DuPont had been acquiring other companies throughout this time, in the 1980s it
participated in the largest merger that the world had seen at that time, joining with Conoco, Inc.
DuPonts final significant product before it joined the worldwide seed market was Stainmaster,

GENETICALLY MODIFIED ORGANISMS AND THE LAW

which made carpets resistant to stains. In 1999, DuPont officially entered the global seed market
by acquiring Pioneer Hi-Bred International, the company that first produced hybrid seed corn. As
a result, DuPont developed into one of the largest genetic engineers of seed plants in the entire
world ("DuPont Company | American Company," n.d.).
Syngenta
Based in Switzerland, Syngenta produces flowers, insecticides, vegetable seeds,
herbicides, field crop seeds, and fungicides. This company was created in 2000 when Novartis
and AstraZeneca wished to escape their biotechnology controversies and save money. Syngenta
thus became the first worldwide group with an exclusive focus on agribusiness. Syngenta opened
its subsidiary in Minnesota, called Syngenta Seeds, in 2009 ("Syngenta," n.d.).
Bayer
Friedrich Bayer founded Bayer AG in Germany in 1863, originally as a dye company.
This company introduced aspirin in its early years and then moved to mass-producing heroin for
cough and pain pharmaceuticals. (Bayer, 2015). Today, in addition to making plastics, overthe-counter drugs, and pharmaceuticals, Bayer is considered one of the most influential
agrochemical companies, along with Syngenta, DuPont and Monsanto ("Bayer," 2014).
Implications
Biotechnology companies patent their GM seeds, so they sue organic farmers whose
crops have been contaminated by them (Crossfield, 2012). In fact, Monsanto devotes $10 million
each year and 75 employees for the sole purpose of the investigation and prosecution of farmers
(Cook, 2012). By controlling the supply of seeds, which essentially means controlling the food
market, top biotech corporations have caused a hazardous blend of ecological, economic, and
political centralization (Cook, 2012). Cook even goes on to say that these companies control
over the food supply is an affront to that very American notion of consumer and producer
choice and voice in the marketplace (2012). He argues that consumers lose their right to
choose which products to buy.

GENETICALLY MODIFIED ORGANISMS AND THE LAW

Political
Lobbying. In 2012 alone, Syngenta contributed over $900,000 to lobbying efforts,
$527,000 of which through its own company, and an additional $400,000 through various
lobbying firms: Alpine Group, Cornerstone Government Affairs, EOP Group, International
Business-Government Counselors, and Podesta Group. Moreover, its lobbying contributions total
for 2012 was less than a fourth of what it spent on lobbying in 2006: $4.36 million. Its total
lobbying expenditures from 2005 to 2012 was over $9.2 million. All of these funds have been
contributed to issues like biotechnology and chemical duty suspensions ("Syngenta," n.d.).
Bayer is another agrochemical company heavily involved in lobbying. In 2013 alone, this
company contributed over $5.5 million in federal lobbying expenditures to combat bills such as
S. 809, the Genetically Engineered Food Right-to-Know Act. The year before, it spent almost
$3.5 million. It is also important to note that some of its executives serve on the American
Legislative Exchange Council. This is a group where special interest representatives collaborate
with corporate lobbyists and elected officials to approve so-called model bills ("Bayer," 2014).
By itself, Bayers lobbying contributions seem overwhelming. However, they are only
fractions of what Monsanto has contributed to lobbying efforts. From 2008 to 2013, Monsanto
spent a total of almost $45 million, and they do not limit themselves to only federal lobbying.
When California attempted to pass Proposition 37, which would have implemented mandatory
labeling of most GMO-containing foods in its state, Monsanto was the top contributor in funds
for defeating the bill, at $8.1 million in spending. Other issues for which Monsanto has lobbied
include the approval of its own RoundupReady sugarbeets and alfalfa ("8 ways Monsanto fails at
sustainable agriculture: #6," n.d.).
Share of the global seed market. Monsanto alone was responsible for the entirety of the
genetically modified alfalfa seed in circulation and for 95% of genetically modified seed of
sugarbeet in 2012 (Crossfield). Monsantos Roundup Ready soybeans, which are genetically

GENETICALLY MODIFIED ORGANISMS AND THE LAW

modified to grow unencumbered by the pesticide Roundup, make up half of all of the soybeans
grown in the U.S. alone ("Bayer," 2014). As a whole, only four companies: Monsanto, DuPont,
Syngenta, and Bayer; own 23% of the entire commercial market for seed ("Bayer," 2014).
Expert opinion. In 1996, one of Monsantos own executives said that the companys
goal was the consolidation of the entire food chain (Chivers, 2014). To achieve this goal,
according to environmentalist George Monbiot, Monsanto has an aggressive patenting regime,
patenting technologies and genetic material (Chivers, 2014). Chivers also believes that genetic
modification and genome patenting give more power to the major corporations; aggressive
patenting is the main concern because it concentrates the power into a select few. He asserts that
the technology itself is not as much of a concern as the control of the technology: The
consequences of GM are more about politics than science (2014). In other words, Monsanto
expands monoculture (Union of Concerned Scientists, n.d.).
Health
The extent of GMOs effects on the human body is unknown because there are no clinical
trials of genetically modified foods on humans. What scientists do know is that GM proteins may
continue to reproduce inside the body after the substances have been digested because genetic
material of GM soy transfers into the humans intestinal bacterial DNA to continue functioning
(Smith, 2008). One essential nutrient for the brain in soybeans is choline. However, Monsanto
GM soy contains 29% less of this nutrient than organic soy. Moreover, a concern for increased
allergies has progressed with the widespread use of genetic modification. One example is that
this Monsanto GM soy contains 27% more of an allergen called trypsin inhibitor than its nonGM counterpart ("Bayer," 2014). Furthermore, cooked genetically modified soy contains roughly
seven times more of this than non-GM soy, according to Smith (2011). GM corn, soy and papaya
fail World Health Organization protein screening protocol for known allergens (Smith, 2008).
Ecological

GENETICALLY MODIFIED ORGANISMS AND THE LAW

Loss of ecological diversity. GM plants may have increased toxicity, meaning that
pollinating animals like bees, butterflies and birds are at risk. In addition, when farmers switch
over to planting GM crops, heritage seeds are put out of use. Less weed flowers grow, meaning
that there is less nectar available for pollinating animals. The amount of bacteria in the soil is
reduced, due to these plants toxicity. These bacteria are what help organic plants grow without
chemical fertilizers. Finally, these problems are distributed to other ecosystems and their
organisms through the air and water, thanks to irrigation (Glass, 2013).
Resistant weeds and chemical use. As of 2013, the USDA found that farmers may use
more than 25 percent more chemicals on each acre of crops that are genetically engineered to
resist herbicides than other crops. Superweeds have developed a chemical resistance to the
main herbicide that farmers use on GM crops, called glyphosate. This causes farmers to
introduce more pesticides to kill off these weeds. Thus, more chemicals are circulating in the
environment as a result of GM farming (Paul & Cummins, 2013).
Cross-pollination. Secretary of Agriculture Tom Vilsack proposed co-existence between
GM farms and organic farmers by using buffers and restricting GM seeds growth
geographically, but experts say that coexistence between GM farms and organic farms is
impossible because of risk of contamination. It is easy for genetic material to be transferred
through pollen and many other means (Crossfield, 2012). Essentially, no matter what efforts of
precaution are taken to prevent the contact of GM seeds with organic farms, cross-pollination is
inevitable to some degree (Cook, 2012). There have been several situations where this has
occurred on a large scale. One notable affair took place in September 2014 when Monsantoengineered experimental wheat was discovered in a field in Montana years after its testing. The
previous year, an Oregon farm experienced a similar predicament. For this case, the USDA could
not locate the source of the wheat, but it occurred eight years after Monsanto finished testing it.

GENETICALLY MODIFIED ORGANISMS AND THE LAW

One percent of the farm was contaminated, but the instance also affected the economy (Bjerga
and Kaskey, 2014).
Economic
Contamination affects the organic food market as a whole because farmers have to put in
additional effort to prevent and test for contamination, thus making organic food more expensive
and threatening the organic food market (Crossfield, 2012). When South Korea, Japan, and
Taiwan learned of the Oregon situation, these countries temporarily stopped importing U.S.
wheat (Bjerga and Kaskey, 2014). The crops that become contaminated by GM seeds can no
longer be labeled as organic (Cook, 2012). Unlike the United States, Europe and Japan label GM
products, so organic farmers are worried that they will lose profits from the foreign markets if
their products test positive for GM strains (Crossfield, 2012).
As of 2013, since farmers first started to buy Monsanto seed in 1995, there has been a
325 percent increase in the average planting cost per acre of soybeans, and there has been a 259
percent increase in the prices of corn seed (Paul & Cummins). Besides the economy, the issue of
contamination by genetically engineered seeds has significantly impacted the legal system.
Case Law
In a 2011 lawsuit, organic farmers attempted to challenge Monsantos seed patents.
Organic Seed Growers & Trade Association et al. v. Monsanto, shortened to OSGTA, sought to
win court-enforced protection for accidental seed contamination. If OSGTA won, innocent
farmers who already have to deal with the economic disadvantages resulting from accidental GM
contamination would no longer be in danger of getting sued by Monsanto. However, the lawsuit
was dismissed before it could even be argued in court. In 2012, OSGTA asked the U.S. Court of
Appeals to reverse the dismissal, but in 2013, the ruling was affirmed. An estoppel order was
given for Monsanto to stop suing farmers just because they could do nothing to prevent trace
amounts of GM material from blowing into organic crop, but OSGTAs goal was full protection,

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something that this estoppel order did not guarantee. The association filed for an appeal a second
time, but once again, it was not granted ("OSGATA Et Al. v. Monsanto," n.d.). If OSGATA
succeeded, it would prevent lawsuits like Monsanto v. U.S. Farmers from ever happening again.
In the 2005 case Monsanto v. U.S. Farmers, Monsanto investigated farmers, settled out of
court, and sued farmers who allegedly infringed on Monsantos patents or breached Monsanto
contract. Up to that date, Monsanto had won $15.3 million from court cases. On average, farmers
paid Monsanto $412,259. This case consisted of 90 lawsuits and involved 25 states, 147 farmers,
and 39 businesses. Two years later, Monsanto sued 112 farmers for the same reasons. In the end,
Monsanto accumulated $21.6 million in damages, plus confidential damages that have not been
disclosed. On average that year, Monsanto collected $385,418 per suit, and the total number
involved rose to 372 farmers and 49 businesses. The Committee on World Food Security (CFS)
estimates a total of $160.6 million paid to Monsanto due to seed piracy lawsuits. CFS executive
director Andrew Kimbrell describes these cases as corporate extortion of American farmers.
He believes that Monsanto profits from its own irresponsibility and negligence by suing
innocent farmers (Wexler, 2011).
Another aspect of patent infringement in the agrochemical realm is seed reuse. The
Monsanto Technology agreement includes two patents: rights to viral genetic material used for
the genetic modification of plants; and the glyphosate herbicide-resistant gene in plants.
According to this agreement, growers can neither use Monsanto seed for more than one season
nor sell the seed to other growers. The only entity that may purchase second-generation seed
from the growers is a grain elevator (Bowman, n.d.). This means that farmers must re-purchase
new seeds every year (Paul & Cummins, 2013).

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In Bowman v. Monsanto, Vernon Hugh Bowman followed the agreement terms at first,
but he began saving second-generation seed from his grain elevator purchase. After discovering
genetic material protected under patent when examining Bowmans crops in 2006, Monsanto
sued Bowman (Bowman, n.d.). He appealed after being ordered to pay Monsanto $84,000
(Paul & Cummins, 2013). Monsanto was granted summary judgement by the district court, and
an affirmation was given by the U.S. Court of Appeals for the Federal Circuit (Bowman, n.d.).
The Supreme Court unanimously responded no to the question, Does a patent right for
self-replicating technology expire after an authorized sale? This means that the Supreme Court
confirmed Monsantos mandate that seeds not be saved because that would be considered
copying a patent-protected item. Thus, Monsantos power has been affirmed by the U.S.
Supreme Court (Bowman, n.d.).
Comparing American and European GMO Labeling
Proposed U.S. Law
As of 2015, no bills proposed in Congress for GMO-labeling have been enacted. S.809 is
an example of this; the proposed law was introduced in the Senate in 2013, and its identical
counterpart in the House was labeled H.R. 1699. Known as the Genetically Engineered Food
Right-to-Know Act, if passed, this bill would have amended Section 403 of 21 U.S.C. 343 (the
Federal Food, Drug, and Cosmetic Act) by adding on clauses to the end that would consider
genetically engineered foods misbranded. The Genetically Engineered Food Right-to-Know
Act explains its purpose as a means to provide consumers knowledge of how their food is
produced for ethical, health, religious, economic, and environmental reasons (S.809, 2014).
Moreover, it explains that over sixty countries already have mandatory GMO labeling, so
enacting this law will help farmers who export their products to these countries. To be considered
genetically engineered, the food must have at least one genetically engineered ingredient or be

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genetically engineered itself. Exceptions include foods served in eateries and foods that are used
for medical reasons. Another important feature of the proposed law was its definition of genetic
engineering: applying certain nucleic acid methods in vitro and the fusion of cells beyond the
taxonomic family that are not traditional techniques and can trump natural barriers to
recombination or reproduction (S.809, 2014).
Unfortunately, there is current risk of a major setback to the GMO labeling movement in
the United States. H.R. 1599 passed the House on July 23, 2015, but it has yet to pass the Senate
and move forward to the President. If this bill is signed into law, it would prevent the
implementation of state GMO-labeling laws, such as the Vermont law below. Its supporters have
named the bill the Safe and Accurate Food Labeling Act of 2015, but its opponents call it the
DARK Act, which stands for Deny Americans the Right to Know. One reason for its
opposition is that it would allow foods that contain GMOs to be labeled as natural.
(McDonnell, 2015)
Vermont Law
To date, no GMO labeling bills have succeeded at the national level, but Vermont is the
pioneer for state labeling law. On May 8, 2014, Vermont signed Bill No. 120 into law. Scheduled
to take effect on July 1, 2016, it defines genetic engineering in a more specific way than the
proposed U.S. law:
a process by which a food is produced from an organism or organisms in which the
genetic material has been changed through the application of: (A) in vitro nucleic acid
techniques, including recombinant deoxyribonucleic acid (DNA) techniques and the
direct injection of nucleic acid into cells or organelles; or (B) fusion of cells (including
protoplast fusion) or hybridization techniques that overcome natural physiological,
reproductive, or recombination barriers, where the donor cells or protoplasts do not fall

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within the same taxonomic group, in a way that does not occur by natural multiplication
or natural recombination (H. 112, 2014).
Under its provisions, genetically engineered packaged raw agricultural commodities will be
labeled as produced with genetic engineering on packaging. Those that are not packaged
separately will be labeled as produced with genetic engineering on the bin or shelf. Processed
food that contains genetically engineered product(s) will be labeled as partially produced with
genetic engineering; may be produced with genetic engineering; or produced with genetic
engineering. These foods cannot be labeled as natural, naturally made, naturally grown,
all natural, or any other similarly misleading words. The exact ingredients that have been
genetically engineered do not have to be labeled as such. The label must also include an FDA
disclaimer that the department does not consider foods produced from genetic engineering to be
materially different from other foods (H. 112, 2014). As stated earlier, this law and similar
labeling laws in other states would be overruled by the DARK Act, if it gets signed into law.
According to Food & Water Watch, over twenty states in the U.S. are considering implementing
labeling laws (2015). Enactment of the DARK Act would eliminate any hope of passing laws
to label GMOs in all of these states.
Europe Labeling Regulations
The first rules for labeling GMOs in foods in Europe were established in 1997, through
the Novel Food Regulation. These regulations were described as proof-based, meaning that
compliance was only verified by testing each final product. Thus, products could not be
determined as made from GMOs if the necessary DNA fragments were no longer intact at the
end of processing ("New labelling laws: What has changed?," 2005).
The current GMO-labeling regulations, called process-oriented, were effected in
Europe, 2004. Now, rather than holding off on GMO testing until the end, food products that

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have directly used GMOs at any point in their creation must follow the labeling requirements.
Under these regulations, GMO-content monitoring is the responsibility of local governments.
Furthermore, for a food to be labeled as containing GMOs, GMO content must be above 0.9
percent. This is considered the threshold for European Union-authorized GM content. In
contrast, if the GMOs are imported, the threshold is now 0.0 percent ("New labelling laws: What
has changed?," 2005). For this reason, organic American farmers who sell their products to the
EU are the most affected by GMO contamination risks.
Conclusion
The subject of GMOs is an issue that expands far past the knowledge of the average
consumer. Not only are Americans shielded from knowing that the foods they regularly eat
contain genetically engineered ingredients, but they also may not be aware that there are only
four companies that control almost the entire industry. Monsanto, DuPont, Syngenta, and Bayer
all play crucial roles in the GMO realm, from manufacturing, to patenting, to lobbying for laws
that benefit their interests and lobbying against laws that would let consumers know that their
products are in the foods they are buying. Time and time again, these corporations have poured
their funds into blocking major legislation that calls for labeling GM ingredients. These
companies also have no problems investing a large amount of resources into suing organic
farmers because they did everything they could to prevent patented GM seed from contaminating
their crops, but that was not enough to stop the inevitability of contamination. Movements to
stop the suing of innocent farmers have also been struck down. At this point, it seems as if the
fight to give consumers the right to know what is in their foods is hopeless, but it is not. If 32
other developed countries around the world have mandatory GMO labeling, with continuous
effort, the United States can too. Vermonts GMO labeling law goes into effect in 2016, so
hopefully it will serve as a model for the nation. This is the first step of many.

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It would be near impossible to try to counteract all of the negative implications of the
GMO industry, but creating a national policy for labeling foods that contain GMOs will help
consumers make better choices. Such a law would create more transparency in the food industry.
When consumers across the nation can finally see which products are genetically engineered and
which ones are not, more and more will opt for non-GMO products, generating less revenue for
biotech companies, thus leveling their power to a fairer proportion.

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References
8 ways Monsanto fails at sustainable agriculture: #6. (n.d.). Retrieved December 4, 2015, from
http://www.ucsusa.org/food_and_agriculture/our-failing-food-system/geneticengineering/lobbying-and-advertising.html#.Vk8bpctdHRM
Bayer. (2014, June 7). Retrieved December 8, 2015, from
http://www.sourcewatch.org/index.php/Bayer#Overview_.26_history_.28subsection.29
Bayer AG. (2015). In Encyclopdia Britannica. Retrieved from
http://school.eb.com/levels/high/article/13869
Bjerga, A., & Kaskey, J. (2014, September 26). Monsanto GMO wheat found in Montana as
Oregon probe ends. Bloomberg. Retrieved December 8, 2015, from
http://www.bloomberg.com/news/2014-09-26/monsanto-gmo-wheat-found-in-montanaas-oregon-probe-ends.html
Bowman v. Monsanto. (n.d.). Oyez. Retreived November 12, 2015, from
https://www.oyez.org/cases/2012/11-796
Brunkow, G. (2012). In defense of Monsanto. In D. A. Miller (Ed.), Genetically engineered
foods (At Issue). Detroit: Greenhaven Press.
Chivers, T. (2014, October 30). GM food: Saving lives, or lining corporate pockets? The
Telegraph. Retrieved from
http://www.telegraph.co.uk/news/earth/agriculture/geneticmodification/11197471/GMfood-saving-lives-or-lining-corporate-pockets.html
Cook, C. D. (2012). Control over your food: Why Monsanto's GM seeds are undemocratic. In D.
A. Miller (Ed.), Genetically engineered foods (At Issue). Detroit: Greenhaven Press.
Crossfield, P. (2012). GM and organic co-existence: Why we really just can't get along. In D. A.
Miller (Ed.), Genetically engineered foods (At Issue). Detroit: Greenhaven Press.
Food & Water Watch. (2015). Member Informational Letter. Washington, DC: Hauter.
DuPont Company | American company. (n.d.). Retrieved December 4, 2015, from
http://www.britannica.com/topic/DuPont-Company
Genetically Engineered Food Right-to-Know Act, S. S.809, 113th Cong. (2014).

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GENETICALLY MODIFIED ORGANISMS AND THE LAW

Glass, E. (2013, August 2). The environmental impact of GMOs. Retrieved December 4, 2015,
from http://www.onegreenplanet.org/animalsandnature/the-environmental-impact-ofgmos/
GMWatch. (2009, February 6). Monsanto: A history. Retrieved December 17, 2015, from
http://www.gmwatch.org/gm-firms/10595-monsanto-a-history
Levow, G. (2015, November 18). [Telephone interview].
McDonnell, S. (2015, September 26). Congress should listen to Americans' desire to label GMO
foods. Retrieved December 14, 2015, from
http://www.fooddemocracynow.org/blog/2015/sep/26-2
New labelling laws: What has changed? (2005, December 15). Retrieved December 4, 2015,
from http://www.gmocompass.org/eng/regulation/labelling/93.new_labelling_laws_gm_products_eu.html
No. 120. An act relating to the labeling of food produced with genetic engineering., H. 112
(2014).
Organic Consumers Association. (n.d.). Information on rBGH or rBST aka Posilac Eli Lillys
genetically engineered bovine growth hormone. Retrieved January 7, 2015, from
https://www.organicconsumers.org/old_articles/rbghlink.php
OSGATA et al. v. Monsanto. (n.d.). Retrieved December 22, 2015, from
http://www.osgata.org/osgata-et-al-v-monsanto/
Paul, K., & Cummins, R. (2013, February 27). Monsanto's patents on life. Retrieved December
22, 2015, from https://www.organicconsumers.org/essays/monsanto%E2%80%99spatents-life
Safe and Accurate Food Labeling Act of 2015, H.R. 1599, 114th Cong. (2015).
Smith, J. (2008, March 1). Spilling the beans: Unintended GMO health risks. Retrieved
December 4, 2015, from https://www.organicconsumers.org/news/spilling-beansunintended-gmo-health-risks

18

GENETICALLY MODIFIED ORGANISMS AND THE LAW

Smith, M. D. (2011). Saying "NO" to GMOs. Better Nutrition, 73(10), 50-51. Retrieved from
http://search.proquest.com/docview/927906677?accountid=3785
Syngenta. (n.d.). Retrieved December 4, 2015, from http://www.sourcewatch.org/index.php?
title=Syngenta
Union of Concerned Scientists. (n.d.). Eight ways Monsanto fails at sustainable agriculture.
Retrieved December 17, 2014, from http://www.ucsusa.org/food_and_agriculture/ourfailing-food-system/genetic-engineering/eight-ways-monsanto-fails.html#.VJIbkeo5DIQ
United States Federal Government. (n.d.). DDT. United States Environmental Protection Agency.
Retrieved January 8, 2015, from http://www.epa.gov/pbt/pubs/ddt.htm
United States Federal Government. (n.d.). Health effects of PCBs. United States Environmental
Protection Agency. Retrieved December 8, 2015, from
http://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/effects.htm
Wexler, B. (2011). Genetic engineering and biotechnology. In Genetics and genetic engineering
(2011 ed., Information Plus Reference Series). Detroit: Gale. Retrieved December 17,
2015, from Gale Databases.
What is GMO? (n.d.). Retrieved December 2, 2015, from http://www.nongmoproject.org/learnmore/what-is-gmo/
Why label? (n.d.). Retrieved December 22, 2015, from http://www.justlabelit.org/right-to-knowcenter/right-to-know/